Data Processing Terms

In order that you as a service provider and data processor (referred to as “Processor” or “you” or “your”) may provide or continue to
provide certain services (the “Services”) to us, LORENZO SANCHEZ-STEWART - NOTARY PUBLIC and data controller (referred to as “Notary Business” or “we”, “us” or “our”), you have agreed that these data
processing terms (“Terms”) shall apply (notwithstanding any other terms and conditions applicable to the delivery of the Services to the contrary) in order to address the compliance obligations
imposed upon the Notary Business and its Clients pursuant to the Data Protection Law. These Terms shall constitute a separate agreement or they may be incorporated by reference in the relevant
Services agreement, as the case may be.

BY ACCEPTING ANY MATERIALS FROM LORENZO SÁNCHEZ-STEWART – NOTARY PUBLIC, THE NOTARY BUSINESS OR OTHERWISE COMMENCING THE SERVICES
(“EFFECTIVE DATE”), YOU AGREE THAT THE PROCESSOR WILL PROCESS NOTARY BUSINESS PERSONAL DATA IN ACCORDANCE WITH THESE TERMS, WHICH YOU HEREBY EXPRESSLY ACCEPT FOR AND ON BEHALF OF THE
PROCESSOR.

NOW IT IS HEREBY AGREED as follows:

1. DEFINITIONS

1.1. In this Agreement, capitalised words shall have the meaning as set out below or, as the case may be, elsewhere in
this Agreement:

“Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under
common control with, a party from time to time during the Term;

“Data Protection Law” means the data privacy laws applicable to the processing in connection with the
Services, including, where applicable, the Directive 95/46/EC, as amended or replaced by any subsequent Regulation, Directive or other legal instrument of the European Union including by the General
Data Protection Regulation or similar law, or the applicable data privacy laws of any other relevant jurisdiction;

“Client” means any client of the Notary Business;

“Contractual Clauses” means the standard contractual clauses of the European Commission for the
transfer of personal data across borders, as amended or replaced from time to time, or any equivalent set of contractual clauses approved for use under Data Protection Law; and

“Notary Business Personal Data” means the personal data processed by Processor in connection with the
Services on behalf of the Notary Business during the Term. The processing may include activities auxiliary to our notarial services, such as other notarial colleagues, postal, courier, legalisation,
translation, hosting, administrative and other services. This will include names and other information about data subjects included in Client materials; and

1.2. The words “data subject”, “personal data”, “processing” and
variations, “controller” and “processor” shall have the meaning attributed to them in Data Protection Law.

2. APPOINTMENT

2.1. The Notary Business is designated by its Clients, Client Affiliates, Notary Business Affiliates and other legal
professionals both within the UK and abroad (collectively “Instructing Parties”) to provide and manage various services, including the Services on their behalf. Accordingly, Notary
Business Personal Data may contain personal data in relation to which Instructing Parties are controllers. Notary Business confirms that it is authorised to communicate to Processor any instructions
or other requirements on behalf of Instructing Parties in respect of processing of Notary Business Personal Data by Processor in connection with the Services.

2.2. Processor is appointed by Notary Business to process Notary Business Personal Data on behalf of the Notary Business and/or the Instructing Parties, as the case may
be, as is necessary to provide the Services or as otherwise agreed by the parties in writing.

3. DURATION

The Terms shall commence on the Effective Date and shall continue in full force and effect until such time as all
Services have ceased and all Notary Business Personal Data in the Processor’s possession or within its reasonable control (including those held by a Subprocessor) has been returned or destroyed (the
“Term”).

4. DATA PROTECTION COMPLIANCE

4.1 In relation to its processing of Notary Business Personal Data, save as otherwise required by law, you agree
to:

process Notary Business Personal Data only as required in connection with the Services and in accordance with our
documented lawful instructions from time to time;

ensure that all personnel authorised by you to process Notary Business Personal Data have committed themselves to
confidentiality or are under an appropriate statutory obligation of confidentiality;

implement appropriate technical and organisational measures to appropriately safeguard Notary Business Personal Data
having regard to the nature of the personal data which is to be protected and the risk of harm which might result from any Security Breach (as defined below), at a minimum the measures set out in the
Schedule;

promptly inform us of any data subject requests under Data Protection Law or regulatory or law enforcement requests
relating to Notary Business Personal Data. You shall not acknowledge or otherwise respond to the subject access request except with our prior written approval, which shall not be unreasonably
withheld;

provide such assistance as the Notary Business may reasonably require in order to ensure our or the Instructing
Parties’ compliance with Data Protection Law in relation to data security, data breach notifications, data protection impact assessments and prior consultations with the Information Commissioner’s
Office or other competent authority;

at our choice, without delay delete or return all Notary Business Personal Data to us, and delete existing copies of
all Notary Business Personal Data in the Processor’s possession or within its reasonable control (including those held by a Subprocessor); and

make available to Notary Business information reasonably necessary to demonstrate your compliance with these Terms
and allow for, and contribute to, audits and inspections carried out by Notary Business.

5. SUBPROCESSORS

5.1. Processor will sub-contract, outsource, assign, novate or otherwise transfer obligations under these Terms or
engage any subcontractors involved in the processing of Notary Business Personal Data (each a “Subprocessor”) only with Notary Business’s prior written consent and subject to clause
5.2.

5.2. When engaging a Subprocessor, Processor will:

carry out reasonable due diligence;

enter into a contract on terms, as far as practicable, same as those in these Terms, and which may include Contractual Clauses to
provide adequate safeguards with respect to the processing of Notary Business Personal Data; and

inform us of any intended changes concerning the addition or replacement of a Subprocessor from time to time. If we object to any such
change on reasonable grounds, then acting in good faith the parties will work together to resolve such objection.

6.2. Processor will notify the Notary Business without undue delay if Processor aware of any Security Breach.

6.3. Processor will investigate the Security Breach and take reasonable action to identify, prevent and mitigate the effects of the Security Breach. Processor will take
such further action as we may reasonably request in order to comply with Data Protection Law.

6.4. Processor may not release or publish any filing, communication, notice, press release, or report concerning any Security Breach ("Notices") without
our prior written approval; such approval shall not be unreasonably withheld.

7. INTERNATIONAL DATA TRANSFERS

7.1. Processor will ensure that no Notary Business Personal Data are transferred out of either:

the European Economic Area; or

any other territory in which restrictions are imposed on the transfer of Notary Business Personal Data across borders
under Data Protection Laws,

without the prior written consent of Notary Business and subject to clause 7.2.

7.2. Notary Business will ensure that Contractual Clauses or other applicable transfer mechanism, such as EU-US
Privacy Shield Framework in relation to EU-US transfers, is in place to ensure adequate level of data protection.

8. INDEMNITY

Notwithstanding any provisions of the relevant Services agreement to the contrary, Processor shall and hereby agrees
to indemnify Notary Business and Instructing Parties and their officers, employees, agents and subcontractors (each an “Indemnified Party”) from and against any claims, losses,
demands, actions, liabilities, fines, penalties, reasonable expenses, damages and settlement amounts (including reasonable legal fees and costs) incurred by any Indemnified Party as a result of any
gross negligence or wilful breach by Processor of these Terms.

9. MISCELLANEOUS

9.1. Clause and other headings in these Terms are for convenience only and shall not affect the meaning or
interpretation of these Terms.

9.2. To the extent of any conflict, these Terms shall prevail over any Services agreement or other
agreement.

9.3. Nothing in these Terms will exclude or limit the liability of either party which cannot be limited or excluded by
applicable law. Subject to the foregoing sentence, (i) these Terms, including any appendices, constitutes the entire agreement between the parties pertaining to the subject matter hereof and
supersedes all prior agreements, understandings, negotiations and discussions of the parties relating to its subject matter; and (ii) in relation to the subject matter of these Terms neither party
has relied on, and neither party will have any right or remedy based on, any statement, representation or warranty, whether made negligently or innocently, except those expressly set out in these
Terms.

9.4. Processor shall agree any amendment to these Terms that may be required from time to time for us and Instructing
Parties to comply with any amended Data Protection Laws.

9.5. All notices of termination or breach must be in English, in writing and addressed to the other party’s primary
contact person or legal department. Notice will be treated as given on receipt, as verified by a valid receipt or electronic log. Postal notices will be deemed received 48 hours from the date of
posting by recorded delivery of registered post.

9.6. Subject to clause 9.2, the Notaries Society is not a party to these Terms and it shall have no liability
whatsoever.

9.7. The provisions of these Terms are severable. If any phrase, clause or provision is invalid or unenforceable in
whole or in part, such invalidity or unenforceability shall affect only such phrase, clause or provision, and the rest of these Terms shall remain in full force and effect.

9.8. These Terms are governed by English law and the parties submit to the exclusive jurisdiction of the English
courts in relation to any dispute (contractual or non-contractual) concerning these Terms save that either party may apply to any court for an injunction or other relief to protect its property or
confidential information.

SCHEDULE: Security measures

Processor shall put in place the following measures, as applicable.

Minimum technical measures

Firewalls which are properly configured and using the latest software;

user access control management;

unique passwords of sufficient complexity and regular expiry on all devices;

secure configuration on all devices;

regular software updates, if appropriate, by using patch management software;